2012 Survey of Lead Paint Regulatory Compliance Among Minnesota Renovators
Executive Summary
Introduction
The U.S. Environmental Protection Agency (EPA) enacted the Renovation, Repair, and Painting Rule (RRP Rule) in
2008, and the Rule became effective in 2010. The RRP Rule protects both children and adults from harmful exposure to
lead by regulating paid work that involves the disturbance of lead paint in housing units and child-occupied facilities built
before 1978. The Rule is currently administered by the EPA in Minnesota. The Minnesota Department of Health’s
Asbestos and Lead Compliance Unit wanted to learn about contractors’ compliance and familiarity with the Rule.
Blood Lead Levels and Screening in Minnesota
Each year, approximately 3,000 children in Minnesota have a venous or capillary blood lead test with a result above 5
µg/dL, the level at which the negative health effects of lead exposure like ADHD, lowered IQ, decreased growth rate, and
behavioral problems can begin to occur. The percentage of blood lead tests above 5 µg/dL varies across the state, with the
Southwest and Southeast regions most heavily affected (4.7% and 3.9% of children tested, respectively). While the
percentage of children who receive a blood lead test before their third birthday is fairly high in the state as a whole
(79.7%), the Northwest region of the state has a substantially lower screening rate (55.8%).
% of Children Tested in 2011 with Results
≥5 µg/dL
5.0%
100%
4.0%
80%
3.0%
60%
2.0%
40%
1.0%
20%
0.0%
0%
% of Children Born in 2008 Screened
Before Age Three
Childhood Lead Poisoning Risk Factors
The primary cause of childhood blood lead levels above 5 µg/dL is the deterioration and disturbance of existing lead
painted or coated surfaces. Homes built before 1950 are especially likely to contain lead hazards, and approximately
550,000 housing units in Minnesota are in this category. The Southwest and Northeast regions have the highest percentage
of housing units built before 1950 (36.9% and 30.1%, respectively). Childhood poverty is another key risk factor for lead
poisoning among children, as families in poverty are more likely to defer maintenance to their homes and have inadequate
nutrition and medical care. The Northeast and Northwest regions of the state have the highest percentage of children
living below the poverty threshold (20.2% and 18.7%, respectively).
Survey Methodology
The invitation to the online survey was sent to 17,000 individuals licensed by the Department of Labor and Industry who
had provided their email address at the time of their licensure, and 230 individuals responded. The limited response rate
means that the results are rough estimates, especially in the Northeast and Southwest regions, where response was lowest.
It is likely that contractors who did not choose to respond are different from those who did, a potential source of error.
The inclusion criteria were that individuals had received payment in the preceding 12 months to perform work that
disturbed paint in housing or child-occupied facilities built before 1978. Participants were asked demographic questions
about their age, county of residence, and employment type, questions about how often they complied with different
requirements of the RRP Rule, and a question about their familiarity with the RRP Rule’s requirements overall.
Contractor Differences
Employees of companies were less compliant with Rule requirements compared to company owners employing more than
two people and sole proprietors who worked alone or with one other person (32.5%, 49.1%, and 45.2% respectively).
Respondents who had taken training to become an EPA-Certified Renovator were substantially more compliant than
respondents who had not (66.0% vs. 14.3%). Respondents under 40 years old were substantially more likely to be
Certified Renovators compared to respondents over 40 (78.4% vs. 52.1%) as well as more likely to be familiar with the
Rule’s requirements (86.8% vs. 76.7%).
Age
Under 40
Differences by Employment Type
Over 40
Employee
100%
Sole Proprietor
>2 Employee Company Owner
100%
80%
80%
60%
60%
40%
40%
20%
20%
0%
Mean
Compliance
Certified
Renovator
Familiar with
RRP
0%
Mean
Compliance
Certified
Renovator
Familiar with
RRP
Regional Differences
Metro region respondents were the most likely to be familiar with the RRP Rule’s requirements (83.8%) and were
compliant the highest percentage of the time (48.3% of the time). Metro respondents were also most likely to have their
firm certified (43.4%). Northeast region respondents were compliant the smallest percentage of the time (17.0%) even
though most respondents were familiar with the Rule’s requirements (72.7%). Respondents in the three least heavily
populated regions of the state (NE, NW, and SW) were the least likely to be familiar with the Rule’s requirements, were
compliant the smallest percentage of the time, and were least likely to have certified their firms. Additionally, over half of
respondents in both the Northeast and Southwest regions were compliant 0% of the time with all requirements of the Rule.
Regional Trends
% of the Time Compliant
% of DoLI Contractors who are EPA
Certified Firms
% of Contractors Familiar with RRP
50%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
40%
30%
20%
10%
0%
SouthwestNorthwest Northeast Central Southeast Metro
(n=11) (n=24) (n=11) (n=21) (n=21) (n=136)
Conclusions
The effects of lead exposure are still felt across the country, including in Minnesota. The RRP Rule has the potential to
lower the rate of blood lead levels that are above 5 µg/dL in Minnesota by reducing lead exposure from renovation, repair,
and painting activities. However, this survey supports the need for increased awareness of and compliance with RRP
requirements among contractors, especially in regions of the state where children are especially at risk for lead poisoning.